Mordialloc Freeway: Submission on the Environmental Effects Statement Expert witness statement by Associate Professor (Dr) Vicki Kotsirilos AM, MBBS, FACNEM, FASLM, Hon Fellow RACGP 16th February 2019 Dunstan Dental & Medical 31 Dunstan St Clayton VIC 3168 PH: 03 95445993 Expert witness for Residents Against Mordialloc Freeway (RAMF) to support its submission to the Mordialloc Freeway Environmental Effects Inquiry. Member (AM) in the General Division of the Order of Australia 2016 o for 'significant service to integrative medicine, to health practitioner standards and regulations, to medical education, and to the environment' Australia Day Environment Award, Bayside City Council 2017 o "Recognising outstanding and long-term leadership, action, and advocacy for coastal and natural heritage protection in the City of Bayside, and generating community awareness of the value of our Bayside environment" Awarded Honorary Fellowship of the Royal Australian College of General Practitioners Honorary Fellow of the Australian College of Nutritional & Environmental Medicine Winner of the Australian General Practice Accreditation Excellence award 2007 Consultant to Federal Government Health bodies such as AHPRA and the Professional Services Review Acknowledgements My sincere gratitude to Associate Professor Louis Irving Director Respiratory and Sleep Medicine, Royal Melbourne Hospital; Visiting Physician, Peter MacCallum Cancer Centre. Professorial Fellow Physiology, Professorial Fellow Medicine, University of Melbourne for providing references and material to assist with the preparation of this expert report. I, Dr Vicki Kotsirilos, am registered as a Specialist General Practitioner with the Medical Board of Australia [AHPRA] and work in Clayton, Melbourne. I reside in the suburb of Sandringham. I am an Honorary Fellow of the Australasian College of Nutritional and Environmental Medicine. I am also an Associate Professor at the University of La Trobe and Western Sydney, and
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Associate Professor (Dr) Vicki Kotsirilos AM, MBBS, FACNEM ......Hon Fellow RACGP 16th February 2019 Dunstan Dental & Medical 31 Dunstan St Clayton VIC 3168 PH: 03 95445993 ... Professorial
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Mordialloc Freeway: Submission on the Environmental Effects Statement
Expert witness statement by
Associate Professor (Dr) Vicki Kotsirilos AM, MBBS, FACNEM, FASLM,
Hon Fellow RACGP
16th February 2019 Dunstan Dental & Medical
31 Dunstan St Clayton VIC 3168
PH: 03 95445993
Expert witness for Residents Against Mordialloc Freeway (RAMF) to support its submission to
the Mordialloc Freeway Environmental Effects Inquiry.
Member (AM) in the General Division of the Order of Australia 2016
o for 'significant service to integrative medicine, to health practitioner standards
and regulations, to medical education, and to the environment'
Australia Day Environment Award, Bayside City Council 2017
o "Recognising outstanding and long-term leadership, action, and advocacy for
coastal and natural heritage protection in the City of Bayside, and generating
community awareness of the value of our Bayside environment"
Awarded Honorary Fellowship of the Royal Australian College of General Practitioners Honorary Fellow of the Australian College of Nutritional & Environmental Medicine Winner of the Australian General Practice Accreditation Excellence award 2007 Consultant to Federal Government Health bodies such as AHPRA and the Professional Services Review
Acknowledgements My sincere gratitude to Associate Professor Louis Irving Director Respiratory and Sleep Medicine, Royal Melbourne Hospital; Visiting Physician, Peter MacCallum Cancer Centre. Professorial Fellow Physiology, Professorial Fellow Medicine, University of Melbourne for providing references and material to assist with the preparation of this expert report. I, Dr Vicki Kotsirilos, am registered as a Specialist General Practitioner with the Medical Board of Australia [AHPRA] and work in Clayton, Melbourne. I reside in the suburb of Sandringham. I am an Honorary Fellow of the Australasian College of Nutritional and Environmental Medicine. I am also an Associate Professor at the University of La Trobe and Western Sydney, and
formerly held an adjunct position at Monash University Department of Epidemiology and Public Health. I have been requested to prepare an expert witness statement related to public health effects
from vehicle emission air pollution by the Residents Against Mordialloc Freeway (RAMF).
RAMF consist of concerned residents residing near the proposed Mordialloc Freeway project.
Furthermore, a number of my own patients live in the vicinity of the proposed 9.7 kilometre
Mordialloc Freeway, in the suburbs of Waterways, Aspendale Gardens and Dingley Village.
My expertise in relation to this matter includes:
1. I keep up to date with research and issues related to chronic diseases and public health, particularly related to lifestyle, physical activity, the environment and nutrition.
2. I treat patients from all age groups with a wide variety of medical conditions in clinical practice. These include patients suffering chronic diseases including asthma, respiratory diseases, cardiac disease and cancers that are directly impacted by road traffic air pollution.
3. I interpret and regularly publish articles based on research into lifestyle and environmental risks affecting general health and chronic diseases, in the general practice setting.
4. I have an interest and expertise in General Medical Health and Environmental Medicine. As a medical practitioner, I have knowledge of the current evidence and first-hand clinical experience of treating patients who are directly or indirectly impacted by poor air quality and pollution. These include children and adults with asthma, chronic lung diseases, heart disease and lung cancer. I directly treat patients who are impacted adversely from living or working near polluted regions.
I declare I have limitations in scientific knowledge on monitoring and how predictions are made
on Concentrations of Pollutants for sensitive receptors against design limits. I am trusting the
predictive values presented in the Mordialloc Bypass (Freeway) Environmental Effects
Statement, Chapter 13 Air quality and greenhouse gas are correct.
However, I do regularly review the scientific literature on epidemiological and cohort studies of
societies and cities based in Australia and in other countries similar to Australia, such as in
Europe and the United States, in relation to how air pollution is becoming a serious widespread
health related issue, and has negative impacts on human health, regardless of whether it meets
State Environment Protection Policy (Ambient Air Quality) Victorian Government SEPP(AAQ)
objectives.
For these reasons I support the local communities opposition of the construction of the
Mordialloc Freeway being built adjacent to, or near an urban environment, and favour instead
funding be diverted to improve public transport for the area. I do not object to freeways
constructed outside of urban areas, but the proposed Mordialloc Freeway would be built in one
of the few remaining green spaces in Melbourne, and adjacent to an urban environment in such
a way that I ascertain will cause short and long term health issues for the residents and workers
of these local communities.
I have attached a review paper I have prepared of the scientific evidence that addresses my
concerns of air pollution to human health to the best of my ability to support this statement,
and why freeways should not be built in urban environments. This scientific document has been
peer reviewed by other medical colleagues and experts in the field.
Members of the community are largely represented within RAMF and some are also my own
personal patients who consult me regularly at my medical clinic in Clayton. These residents
currently enjoy predominately fresh air being surrounded by local parklands and clean local
suburbs. They are experiencing great fears about the health implications of building a freeway
next to or near their homes, and the impact this would have on their health. Those with pre-
existing health conditions such as cardiac disease, lung disease and asthma, and the more
vulnerable and susceptible, such as people with pre-existing illnesses, children, the elderly and
pregnant women are most at risk of harm as demonstrated in studies included in my scientific
report attached.
The RAMF have invited me to present as an Expert Witness and have asked me to address the
following questions in relation to the EES for the construction of the proposed Mordialloc
Freeway:
1. Does the Mordialloc Freeway Project EES adequately identify and respond
appropriately to the most current scientific evidence and literature in relation to
health impacts from air pollution?
Is there evidence that the Mordialloc Freeway constructed next to an urban
residential area may impact the health of the local residents who live or work in the
area?
2. How may air pollution from vehicle emissions impact the health of the local
residents?
3. Have the potential health concerns to the local community been adequately
addressed in the submission in view that a total of 266, 450, 000 vehicles are
expected to have travelled along the freeway by the year 2031 (based on project
approximate average of 73 000 vehicles per day, over the 10 year period)?
4. Do you believe the local residents have been adequately informed of the vehicle
emissions and health impacts?
5. Does the EES address Air Quality adequately to protect human health having regard
to the evolving science in relation to health impacts from air pollution?
The State Environment Protection Policy (Ambient Air Quality) SEPP(AAQ) includes objectives for 24 hour average and annual readings2: PM10 concentrations of 50 μg/m3 (24 hour average) and 20 μg/m3 (one year average) PM2.5 objective of 25 μg/m3 (24-hour average) and 8 μg/m3 (one year average). The Environmental Quality Objectives for PM2.5 have been further revised and lowered to 7micrograms/cubic metre per year as tabled in the EPA website:3
There is now an abundance of worldwide literature including public health alerts by authorities such as the World Health Organisation, that highlight strong data and research outcomes demonstrating immediate and long term adverse effects on human health, from Particulate Matter traffic related air pollution, occurring at a greater magnitude of impact than previously thought, now demonstrating there is no safe lower limit of exposure4,5 . These concerns are well described in a number of studies conducted in Europe, the United States and Australia i.e. in areas of equivalent air pollution experienced in cities and urban areas of Australia that experience high traffic volumes such as Melbourne are described throughout this document and in the attached scientific report.
2 Extracted pages 23-25 of Appendix F Government of Victoria, 1999, February. State Environment Protection Policy
(Ambient Air Quality) Victorian Government Gazette, No S19. Government of Victoria, 2001, & State Environment Protection
Policy (Air Quality Management), SEPP(AQM). Victorian Government Gazette, No S240.
3 EPA Victoria SCHEDULE 2 – ENVIRONMENTAL QUALITY OBJECTIVES AND GOAL. Table 1: Environmental quality
objectives for environmental indicators. https://www.epa.vic.gov.au/about-us/legislation/~/media/Files/About%20us/Legislation/Air/160726consolidatedvariedSEPPAAQ.pdf
4 Qian Di, M.S, Wang Y, Zanobetti A, Wang Y, Koutrakis P, Choirat C, Dominici F, Schwartz JD. Air Pollution and
mortality in the Medicare Population. N Engl J Med 2017, June 29; 376(26):2513-2522. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5766848/
5 Barnett A. It’s safe to say there is no safe level of air pollution. Australian and New Zealand Journal of Public
Recent studies now demonstrate even level of PM2.5 exposure below National Environment Protection (Ambient Air Quality) Measures and SEPP (AAQ) Objectives (as described above) are considered to cause detrimental impacts on health6. The World Health Organisation air quality guidelines state, “there is little evidence to suggest a
threshold below which no adverse health effects would be anticipated”7.
Therefore we should be aiming at ensuring the cleanest air possible.
The Environmental Protection Agency has also provided comment on the technical and
scientific aspects of the Mordialloc Bypass (Freeway) EES8. On page 10 of their submission
under section 3.1 titled "Air Quality EPR AQ1" they acknowledge: "There is well established
scientific evidence that traffic related air pollution, even at concentrations well below the current air
quality standards, is associated with adverse health effects."
"(Air quality (operation)). Traffic is a significant contributor to air pollution in Melbourne. It generates air
pollution from both exhaust emissions and non-exhaust emissions (from tyres, brakes and road). There is
well established scientific evidence that traffic related air pollution, even at concentrations well below
the current air quality standards, is associated with adverse health effects. As stated above in Section
2.2.7, EPA recommends the use of the SEPP (AAQ) Schedule 2 - environment air quality objectives to
compare and assess air pollution levels measured near roads. EPA also recommends proponents to
adopt best practice design and controls to reduce air pollution and human health impacts. For new or
upgrades of major roads, the requirement of applying demonstrated best practice design and controls
that reduce air pollution impacts with risk assessments using the SEPP(AAQ) objectives should be
adopted. This is consistent with the regulatory approach in other jurisdictions in Australia and
internationally. The feasibility and viability exist to implement best practice design and controls to
reduce air pollution impacts to meet the SEPP(AAQ) objectives."
6 Diana Phillips Even 'Safe' Levels of Air Pollution Tied to Higher Mortality -Medscape–Dec 27, 2017.
https://www.medscape.com/viewarticle/890636
7 World Health Organization. Air Quality Guidelines for Particulate Matter, Ozone, Nitrogen Dioxide and Sulfur
Dioxide: Global Update 2005. Geneva (CHE): WHO; 2006. https://go.galegroup.com/ps/i.do?p=AONE&sw=w&u=googlescholar&v=2.1&it=r&id=GALE%7CA174061909&sid=classroomWidget&asid=acec1d40
So as an example if we look at Table 13.10 Predicted peak values for PM2.5 per hour at the Hawthorn Football club in Heatherton (location number 1 in Table 13.10) the expected peak level of exposure is 16 micrograms per cubic metre in a 1 hour period. The football club attracts children and families. The players exercise in this environment. Exercise results in deep breathing and increase in respiratory rate.
Drawing from the Hazard risk chart above9 the risk of harm to these individuals being exposed to PM2.5 at 16 micrograms/m3 is nearly 1.10. That is there is a 10% chance of increasing their risk of mortality (earlier death) above expected general population mortality due to air pollution alone! However, the population at the Football club is transient. People come and go to observe, train, exercise and play football. The age groups vary from young to old, and the health status of those people also varies. So the risk and impact is hard to determine in a transient changing community.
However, when we explore Table 13.10 for other locations, the residents of Waterways [note Aspendale Gardens is a misprint in this location 11], ), the workers at Commercial Dingley (location 3), Parks Victoria office lunchroom (location 8), the elderly residing at Ritchfield Retirement (location 14) and Chelsea Village Retirement Village (location 15) are exposed at or above the levels of 20 micrograms PM2.5 per cubic metre in a 1 hour period. Their risk of harm (mortality) exceeds 1.10 ie possibly a greater than 10% chance of increasing their risk of mortality (earlier death) compared to the general population due to exposure of air pollution alone! Again there are variables and a direct conclusion cannot be made, but the elderly would be a particularly high risk group due to most having pre-existing health conditions, they are not a transient group i.e. they remain on site at all or most times, and are a susceptible group for impacts to health from air related traffic pollution. People working in the Commercial Dingley region who spend the whole day at work with ongoing daily exposure to traffic related air pollution are also a high risk group. If any of the workers have other risk factors such as smoking or pre-existing lung conditions such as asthma, would be a high risk for exacerbation of asthma, risk of lung infections or chronic lung disease.
Furthermore the level of air pollution will vary during the day with peak hour traffic creating the higher levels, and most likely will increase over time as the population grows leading to a rise in Total Vehicle Numbers and consequently impact air quality.
Table 13.10 does not explore childcare and kindergarten centres located near the vicinity of the proposed Mordialloc Freeway, and calculating the Predicted peak concentrations of air pollutant exposure to the local children. A simple google search of the internet locates a number of childcare centres in the nearby vicinity that may be impacted with changes in air quality from the proposed Freeway:
9 Figure 3 Concentration–Response Function of the Joint Effects of Exposure to PM2.5 and Ozone on All-Cause
Concerning all cause mortality, studies by Lepeule 201210 and Beelan11 2014 are also large
cohorts that give robust estimates of mortality due to long term exposure to air pollution. Both
of these more recent studies included relatively low levels of exposure to small particulate
matter (PM 2.5) similar to locations near the proposed Mordialloc Freeway project. However,
the researchers demonstrated an increase in mortality related to exposure to PM 2.5, even at
lower concentrations.
10
Lepeule J., Laden F., Dockery D. and Schwartz J. (2012). Chronic exposure to fine particles and mortality: an extended follow-up of the Harvard Six Cities study from 1974 to 2009. Environ Health Perspect 2012 Jul;120(7):
11 Beelen R., Raaschou-Nielsen O., Stafoggia M., Andersen Z.J., Weinmayr G., Hoffmann B. et al. (2014a). Effects of
long-term exposure to air pollution on natural-cause mortality: An analysis of 22 European cohorts within the multicentre ESCAPE project. The Lancet 383(9919): 785-795. https://www.ncbi.nlm.nih.gov/pubmed/24332274
The Lupeule study based in Harvard USA for instance found since 2001, average PM2.5 levels, for
all six cities studies, were < 18 µg/m3. Each increase in PM2.5 (10 µg/m3) was associated with an
adjusted increased risk of all-cause mortality (PM2.5 average on previous year) of 14% , and with
26% and 37% increases in cardiovascular and lung-cancer mortality (PM2.5 average of three
previous years), respectively. The concentration–response relationship was linear down to
PM2.5 concentrations of 8 µg/m3.
Pope et al JAMA 2002
A study published by Pope et al JAMA 2002 demonstrated similar concerns that are well illustrated in the diagrams below which demonstrate increase mortality and morbidity with increasing level of exposure to PM2.5 well below current Australian Government standards and Objectives12:
12
Pope CA 3rd, Burnett RT, Thun MJ, Calle EE, Krewski D, Ito K, Thurston GD. Lung cancer, cardiopulmonary mortality, and long-term exposure to fine particulate air pollution. JAMA. 2002 Mar 6;287(9):1132-41. https://www.ncbi.nlm.nih.gov/pubmed/11879110
Mordialloc Freeway Project EES data Data listed in Table 13.3 in chapter 13 page 13-5, listing predicted vehicle emissions of the proposed project route using SEPP (AQM) design criteria concentrations (1 hour averaging period) are still concerning when there is research to demonstrate that any level of pollutants are a risk to human health i.e. there is no safe level of PMs: Chapter 13, page 13-10
Australian and International studies demonstrate air pollution harms human health, particularly
in susceptible people, are well below the current levels of pollutants as listed in Table 13.3.
There is no safe lower limit of air pollution - even below SEPP(AQM) 1 hour design criteria
(microgram/m3) concentration guidelines for pollutants.
The EES page 13-1 asserts that "...Carbon monoxide and PM (PM10 and PM2.5) are expected
to have minor to negligible air quality impacts.."
My response to the EES conclusions:
I do agree that vehicle emissions may be less than the SEPP (AAQ) Objectives and Goals, but I
do not agree with the above statements as stated on pages 13-1 and 13-13 that ""...Carbon
monoxide and PM (PM10 and PM2.5) are expected to have minor to negligible air quality
impacts..". I believe the studies as described above demonstrate that the levels quoted in table
13.3 (page 13-10) and Table 13.10 (page 13-19) as illustrated above are concerning.
It is likely there will be regions with less air pollutant levels along the proposed freeway, such as
when vehicles are cruising at the same speeds but with the increase in population and
consequent increase in total number of vehicles on the freeway, weather and wind influences ,
breaking and accelerating there is likely to be certain areas that are "hot spots" i.e. more
pollutant load.
Whilst vehicles are likely to reduce emission rates per vehicle [table 13-9 page 13-19], there is
likely to be higher levels of total emissions overall brought about by the increase in number of
vehicles from the increase in population despite improvement in emissions generated by each
vehicle.
With the expected growth of the number of vehicles on the road, areas such as Waterways,
Dingley and Aspendale Gardens will experience a substantial growth in Total Vehicle Numbers,
which will result in significant rise in total vehicle emissions in these areas especially with
expected population growth.
Hibrid and Electric cars
The claim on page 13-18 of Chapter 13 states:
"Calculated average fleet emission factors for 2031 are shown in the Table 13.9. There is potential for
emission rates from 2031 to be considerably lower than shown in Table 13.11 as vehicles become more
fuel efficient and especially if hybrid and electric vehicles become more widely used. There has been a
substantial reduction in vehicle emission rates over the last decade and a further reduction is projected
until the year 2021. Based on this trend, it is reasonable to expect a further substantial reduction by the
year 2031."
It is correct that each vehicle emissions are improving overall, but I cannot find the evidence for claiming
"reasonable to expect a further substantial reduction" when currently Australia is lagging in terms of
electric vehicle take-up, now making up only just 0.2 per cent of Australian cars according to data from
Australia's Electric Vehicle Council (EVC).
The studies cited above are further extrapolated and discussed within my scientific report
attached.
2. How may air pollution from vehicle emissions impact the health of the local residents?
There is clear evidence that air pollution due to vehicle emissions is a cause of a number of
health problems including increased risk of mortality. Harm to human health occurs at levels
below National Environment Protection (Ambient Air Quality) Measures and SEPP
(AAQ) Objectives that are currently . This is well described above and in my scientific report
attached.
Traffic related air pollution, even at low levels contributes to and/or causes a number of health problems especially for individuals living and working near freeways. Studies conducted in Europe, the United States and Australia i.e. in areas of equivalent air pollution experienced in cities of Australia such as Melbourne, are described throughout this document even when considered "safe" thresholds demonstrating detrimental impacts on health13.
None of the studies cited in this document or the attached scientific paper are cited in the Mordialloc Freeway Project EES warning local residents, particularly susceptible groups who will experience an unprecedented rise in air pollution levels from the proposed freeway eg residents living and working in Aspendale Gardens, Waterways and Dingley village. There are also a number of international studies in countries experiencing enormous growth in traffic congestion such as China. These studies demonstrate real health risks. We need better 21st century solutions to avoid Australia falling into the same situation. Short and long term exposure health effects to ambient PM exposure
Below is tabled a summary of potential health effects from short and long term exposure to ambient PM exposure14:
13
Diana Phillips Even 'Safe' Levels of Air Pollution Tied to Higher Mortality -Medscape–Dec 27, 2017.
https://www.medscape.com/viewarticle/890636
14 Hime, H., C. Cowie, and G. Marks, Review of the health impacts of emission sources, types and levels of
particulate matter air pollution in ambient air in NSW, N.E.P. Authority and E.H.B. NSW Ministry of Health,
Editors. 2015, Woolcock Institute of Medical Research, Centre for Air Quality and Health Research and Evaluation
Morawska, Lidia (2014) School children’s personal exposure to ultrafine particles in the urban environment.
Environmental Science & Technology (including News & Research Notes), 48(1), pp. 113-120
16 Bowatte, G., et al., The influence of childhood traffic‐related air pollution exposure on asthma, allergy and
sensitization: a systematic review and a meta‐analysis of birth cohort studies. Allergy Cochrane Library. 2015. p. 245-256. https://onlinelibrary.wiley.com/doi/full/10.1111/all.12561
17 Gasana J, Dillikar D, Mendy A, Forno E et al. Motor vehicle pollution and asthma in children: a meta-analysis.
Environ Res. 2012, Aug; 117: 36-45. https://www.ncbi.nlm.nih.gov/pubmed/22683007
Another systematic review of epidemiological studies in children whose mothers were exposed
to air pollution [prenatal exposure] found the child was at increased risk of developing asthma:
"The overall and subgroup risk estimates from the meta-analyses showed statistically significant
associations between prenatal exposures to NO2, SO2, and PM10 and the risk of wheezing and
asthma development in childhood."18
The European Study of Cohorts for Air Pollution Effects (ESCAPE) project analyzed data from
birth cohort studies situated in Germany, Sweden, the Netherlands, and the United Kingdom
that measured lung function at 6-8 years of age (n = 5,921)19. The researchers found children
exposed to NO2, NOx, PM2.5 absorbance, and PM2.5 from air pollution traffic was associated
with reduced lung function and lung development at an early age. A second ESCAPE study in
2014 showed an increase in respiratory infections in early childhood for some components of
traffic pollution20.
Decreases in adverse health outcomes such as hospital admissions for asthma, the prevalence
of bronchitis in children and improved lung function in children, have been observed with
decreases in particulate matter following major interventions to reduce air pollution21,22,23.
Systemic inflammation in children
Systemic inflammation of the body can be measured by a blood test called C-Reactive Protein.
This is an inflammatory marker and an Australian, Brisbane study found high levels in children
18
Hehua Z, Qing C, Shanyan G, Qijun W, Yuhong Z. The impact of prenatal exposure to air pollution on childhood wheezing and asthma: A systematic review. Environ Res. 2017 Nov;159:519-530. doi: 10.1016/j.envres.2017.08.038. https://www.ncbi.nlm.nih.gov/pubmed/28888196
19 Gehring U, Gruzieva O, Agius RM, Beelen R, et al. Air pollution exposure and lung function in children: the
ESCAPE project. Environ Health Perspect. 2013 Nov-Dec;121(11-12):1357-64. doi: 10.1289/ehp.1306770. Epub 2013 Sep 27. https://www.ncbi.nlm.nih.gov/pubmed/24076757/
20 MacIntyre E, Gehring U, Fuertes E, Klumper C et al. Air pollution and respiratory infections during early
childhood: an analysis of 10 European birth cohorts within the ESCAPE project. Environ Health Perspect. 2014 Jan;122(1) 107-13. https://www.ncbi.nlm.nih.gov/pubmed/24149084
21 Pope C.A. (1989). Respiratory disease associated with community air pollution and a steel mill, Utah Valley.
Am J Public Health 79: 623-628. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1349506/
22 Heinrich J. (2003). Nonallergic respiratory morbidity improved along with a decline of traditional air pollution
levels: A review. European Respiratory Journal 21(Supplement 40): 64S-69s. https://pdfs.semanticscholar.org/381c/dcf4b6e305a8b3459c5ecdce05a842410b1a.pdf
23 Gauderman WJ, Urman R, Avol E, et al. Association of Improved Air Quality with Lung Development in Children
aged 8-11 years caused from exposure to the ultrafine particles smaller than 0.1 μm that
penetrate deeper into the lung and circulatory system24. The implications of chronic
inflammation found in children are enormous as the long term effects of chronic systemic
inflammation are known to contribute to a number of health conditions.
Pregnancy exposure & Low Birthweight
Data from the ESCAPE study in 2013 demonstrated that exposure to PM 2.5 during pregnancy
was associated with an increased risk of low birthweight on infants born at term, even at levels
of PM 2.5 less than the current EU annual limit of 25 ug/m3 25. This study concluded that “a
substantial proportion of cases of low birthweight at term babies could be prevented in Europe
if urban air pollution was reduced”.
Air pollution effects on elderly
In the US Medicare population from 2000 to 2012, short-term exposures to PM2.5 and warm-
season ozone found elderly to be of significant risk of mortality even at levels below current
national air quality standards, suggesting that these standards may need to be reevaluated26.
A proposed shared-use trail for cyclists and pedestrians built beside the Mordialloc freeway
Those more at risk to health impacts from traffic related air pollution are cyclists and
pedestrians on trails built along the proposed Freeway, residents living adjacent to these roads
and occupational workers working in close proximity to heavy traffic causing air pollution.
There is no evidence within the EES that warns these residents or workers or cyclists or
pedestrians using the trail of potential harms to their health from exposure of higher
concentrates of air pollution that will occur with the proposed Mordialloc Freeway particularly
in regions of 'hot spots' and in areas of higher volume of vehicle traffic.
There is evidence that exercising in traffic pollution increases the risk of cardiovascular disease
so constructing a pedestrian and bike path along the proposed Mordialloc freeway is
24
Clifford S, Mazaheri M, Salimi F, Ezz WN, Yeganeh B, Low-Choy S, Walker K, Mengersen K, Marks GB, Morawska L. Effects of exposure to ambient ultrafine particles on respiratory health and systemic inflammation in children. Environ Int. 2018 May;114:167-180. doi: 10.1016/j.envint.2018.02.019. Epub 2018 Mar 4. https://www.ncbi.nlm.nih.gov/pubmed/29514111
25 Pedersen M, Giorgis-Allemand L, Bernard C, et al. Ambient air pollution and low birthweight: a European
detrimental to users of the path. A systematic review of 18 studies calculated the health
impacts based on exposure-response of cyclists to air pollution and found significant health
concerns were associated with exposure to ozone, black carbon or nitrogen oxides from cycling
on heavily polluted roads.27
Motorists also at risk of Vehicle related Air Pollution
Not considered by the Mordialloc Freeway Project EES is also the potential harm to motorists being exposed to air pollution particularly those who rely on transport for work, whose vehicles do not have appropriate air filters, and use heavily congested roads such as freeways frequently. A study found overall, car commuters had higher exposure to all pollutants than those who commuted by bus, motorcycles, followed by a car with controlled ventilation settings and those who use public transport [ie, train, subway, or metro]28. A randomised double-blind study was conducted in men with a known history of stable coronary heart disease found exposure to dilute diesel (300 micrograms/m3) exhaust in patients during 1 hour of moderate exercise had a direct effect on myocardial function [ECG changes], vascular, and fibrinolytic function29. The study found cardiac changes ie angina with ECG changes when breathing air with a small amount of diesel exhaust compared with breathing clean filtered air.
As the number of vehicles on the proposed Mordialloc Freeway increases, it will be impossible
for pedestrians and cyclists to use the shared trail due to air pollution emitted from vehicles,
combined with noise pollution.
Specific diseases caused by Air Pollution exposure:
Lung Cancer
The EES has not incorporated any studies that demonstrate that air pollution is an important
cause of lung cancer. Lung cancer incidence is rising in Australia. The Australian Government
27
Raza W, Forsberg B, Johansson C, Sommar JN. Air pollution as a risk factor in health impact assessments of a
travel mode shift towards cycling. Glob Health Action. 2018;11(1):1429081. doi:
state air pollution amongst other risks as a cause of lung cancer30. International Agency for
Research in Cancer (IARC), a division of the World Health Organisation (WHO), raised the alarm
in 201331. Also in 2013, one of the studies from the European Study of Cohorts for Air Pollution
Effects (ESCAPE), by Raaschou-Nielsen et al32, showed that exposure to PM 10 and PM 2.5
increased the risk for lung cancer. A meta-analysis of 18 studies by Hamra in 201433 confirmed
the carcinogenic nature of outdoor exposure to PM 10 and PM 2.5. A second meta-analysis by
Chen et al in 201534 included 22 studies involving occupational exposure to air pollution among
professional drivers. Again exposure to fine particulate matter increased the risk of lung cancer,
and the risk was greater in professional drivers than in other people. IARC currently lists diesel
engine exhaust and particulate matter as class 1 carcinogens. Because of the poor survival from
lung cancer in Australia (< 14% of sufferers are alive after 5 years), it is essential that
preventable causes, including air pollution, are minimized.
Cardiovascular disease
There are a number of other significant adverse health effects of traffic pollution that have not
been explored or considered in the EES. Important examples are the acute and chronic
cardiovascular effects from exposure to pollution35,36. Dennekamp et al is a study performed in
Melbourne in 2010, and confirmed studies from other cities (including Perth) showing that
30
What are the risks of Lung Cancer? Australian Government, Cancer Australia https://lung-cancer.canceraustralia.gov.au/risk-factors 31
IARC Monograph 109, 2013.
32 Raaschou-Nielsen, Andersen, Beelen, Samoli, Stafoggia, Weinmayr, et al. (2013). Air pollution and lung cancer
incidence in 17 European cohorts: Prospective analyses from the European Study of Cohorts for Air Pollution Effects (ESCAPE). Lancet Oncology, 14(9), 813-822. https://www.thelancet.com/journals/lanonc/article/PIIS1470-2045(13)70279-1/fulltext
33 Hamra, G., Guha, N., Cohen, A., Laden, F., Raaschou-Nielsen, O., Samet, J, Loomis, D. (2014). Outdoor Particulate
Matter Exposure and Lung Cancer: A Systematic Review and Meta-Analysis. Environmental Health Perspectives, 122(9), 906-911. https://www.ncbi.nlm.nih.gov/pubmed/24911630
34 Gongbo Chen,
1 Xia Wan,
2 Gonghuan Yang,
2 and Xiaonong Zou
1 Traffic-related air pollution and lung cancer: A
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events: prospective cohort study and meta-analysis in 11 European cohorts from the ESCAPE Project. BMJ. 2014 Jan 21;348:f7412. https://www.ncbi.nlm.nih.gov/pubmed/24452269
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when the ambient concentration of PM2.5 increased, there was a corresponding increase in
out-of-hospital cardiac arrests. There is now a possible biological explanation for this
association, with recent data from the Framingham Heart Study showing that short term
exposure to air pollution generates a systemic inflammatory response, which is linked to
cardiac disease37.
Stroke
A major study published by Feigin et al in 2016 looked at risk factors for stroke in 188 countries.
The researchers estimate that globally, nearly one third of all strokes are attributable to air
pollution38.
In summary the evidence clearly demonstrates air pollution has the following effects:
1. Increases morbidity and mortality especially from fine particulate air pollution ie earlier
deaths from global studies performed in cities exposed to ambient air pollution39,40,41,42
2. Increase mortality associated with long-term effect of nitrogen dioxide NO2 as great as
that of PM2.543
37
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38 Feigin, Valery L., et al. Global burden of stroke and risk factors in 188 countries,during 1990–2013: a systematic
analysis for the Global Burden of Disease Study. 2013. The Lancet Neurology 15.9 (2016): 913-924. https://www.ncbi.nlm.nih.gov/pubmed/27291521
39 Qian Di, MS; Lingzhen Dai, ScD; Yun Wang PhD; et al Antonella Zanobetti, PhD; Christine Choirat, PhD; Joel D.
Schwartz, PhD; Francesca Dominici, PhD Association of Short-term Exposure to Air Pollution With Mortality in
40 C. Arden Pope III, Ph.D., Majid Ezzati, Ph.D., and Douglas W. Dockery, Sc.D. Fine-Particulate Air Pollution and
Life Expectancy in the United States. New England Journal of Medicine 360;4 nejm.org january 22, 2009 pages 376-386. https://www.nejm.org/doi/full/10.1056/NEJMsa0805646
41 Romieu I, Gouveia N, Cifuentes LA, de Leon AP, Junger W, Vera J, Strappa V, Hurtado-Díaz M, Miranda-Soberanis
V, Rojas-Bracho L, Carbajal-Arroyo L, Tzintzun-Cervantes G; HEI Health Review Committee. Multicity study of air
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https://www.ncbi.nlm.nih.gov/pubmed/23311234
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Air and Waste Management Association 56:709–742. https://www.tandfonline.com/doi/abs/10.1080/10473289.2006.10464485
4. Increase risk of heart failure due to a possible threshold of PM2.5=4 µg/m3 is far below
the daily Australian national standard of 25 µg/m3 50
5. Higher risk of developing hypertension [high blood pressure]51,52.
43
Faustini A, Rapp R, Forastiere F. Nitrogen dioxide and mortality: review and meta-analysis of long-term studies.
Eur Respir J. 2014 Sep;44(3):744-53. https://www.ncbi.nlm.nih.gov/pubmed/24558178
44 Qian Di, MS; Lingzhen Dai, ScD; Yun Wang, PhD; et al Antonella Zanobetti, PhD; Christine Choirat, PhD; Joel D.
Schwartz, PhD; Francesca Dominici, PhD Association of Short-term Exposure to Air Pollution With Mortality in Older Adults JAMA. 2017;318(24):2446-2456.doi:10.1001/jama.2017.17923 https://jamanetwork.com/journals/jama/article-abstract/2667069
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47 Baccarelli A, Martinelli I, Zanobetti A, et al. Exposure to Particulate Air Pollution and Risk of Deep Vein
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50 Huynh QL, Blizzard CL, Marwick TH, et al. Association of ambient particulate matter with heart failure incidence
and all-cause readmissions in Tasmania: an observational study. BMJ Open 2018;8:e021798. doi: 10.1136/bmjopen-2018-021798 https://bmjopen.bmj.com/content/8/5/e021798
51 Cai Y, Zhang B, Ke W, Feng B, Lin H, Xiao J, Zeng W, Li X, Tao J, Yang Z, Ma W, Liu T. Associations of Short-Term
and Long-Term Exposure to Ambient Air Pollutants With Hypertension: A Systematic Review and Meta-Analysis. Hypertension. 2016 Jul;68(1):62-70. doi: 10.1161/HYPERTENSIONAHA.116.07218. Epub 2016 May 31. https://www.ncbi.nlm.nih.gov/pubmed/27245182
Yang BY, Qian Z, Howard SW, Vaughn MG, Fan SJ, Liu KK, Dong GH. Global association between ambient air pollution and blood pressure: A systematic review and meta-analysis. Environ Pollut. 2018 Apr;235:576-588. doi: 10.1016/j.envpol.2018.01.001. Epub 2018 Jan 11. https://www.ncbi.nlm.nih.gov/pubmed/29331891
53 Shah AS, Lee KK, McAllister DA, Hunter A, Nair H, Whiteley W, Langrish JP, Newby DE, Mills NL. Short term exposure to air pollution
and stroke: systematic review and meta-analysis. BMJ. 2015 Mar 24;350:h1295. doi: 10.1136/bmj.h1295. https://www.ncbi.nlm.nih.gov/pubmed/25810496 54
Yang WS, Wang X, Deng Q, Fan WY, Wang WY. An evidence-based appraisal of global association between air pollution and risk of stroke. Int J Cardiol. 2014 Aug 1;175(2):307-13. doi: 10.1016/j.ijcard.2014.05.044. Epub 2014 May 17. https://www.ncbi.nlm.nih.gov/pubmed/24866079
55 Cohen G, Levy I, Yuval, Kark JD, Levin N, Broday DM, Steinberg DM, Gerber Y. Long-term exposure to traffic-related air pollution and
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56 Lahn Straney, Judith Finn, Martine Dennekamp, Alexandra Bremner, Andrew Tonkin, Ian Jacobs. Air pollution
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61 Kim H, Bernstein JA. Air Pollution and Allergic Disease. Curr Allergy Asthma Rep. 2009 Mar;9(2):128-33
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skills, particularly in the elderly, potentially resulting in significant health and economic
costs. Multiple studies suggest air pollution contributes to cognitive impairment71,72,73
15. Increased mortality due to residents working or residing in industrial areas of high air
pollution resulting in increase cancers, lung cancer, mortality and neurological
diseases74.
16. Increase sick leave from work75.
17. Greater healthcare utilisation by both children and adults for respiratory infections76.
18. Increased risk of hospitalisation due to pneumonia in children77.
19. Increased risk of type 2 diabetes and diabetes associated mortality78,79,80
20. Pregnancy risks -fine particulate chemicals from air pollution impact the blood vessel
barrier of the vascular system of the placenta causing low birth weight, preterm birth,
71
Clifford, A., et al., Exposure to air pollution and cognitive functioning across the life course – A systematic
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72 Oudin, A., et al., Traffic-Related Air Pollution and Dementia Incidence in Northern Sweden: A Longitudinal Study.
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21. small for gestational age, and adverse birth outcomes81,82,83 and may increase
stillbirths84,85.
22. Poor sperm quality and infertility86.
23. Non-lung cancers: PM2.5 was significantly positively associated with death from cancers
of the kidney and bladder. NO2 was positively associated with colorectal cancer
mortality87.
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Page 13-12 Figure 13.4 Air quality sensitive receptors, EES Chapter 13 (next page):
Note distance of the residents and commercial regions in illustration above Figure 13.4 Page
13-12 of EES Chapter 13 those at highest risk due to proximity to the proposed freeway:
Commercial Dingley number 3 situated at 25 metres
Residential Dingley numbers 4/5 at 36 metres
Commercial Dingley number 6 at 33 metres
Residential Waterways number 11 at 30 metres
Richfield Retirement, Aspendale Gardens number 14 at 32 metres
Retirement Village, Chelsea Heights number 15 at 30 metres
Those most susceptible living in these retirement centres is the elderly
The EES Mordialloc Freeway project EES has not listed the locations of the local schools and
childcare centers. In view of the high risk to children, it is paramount, that the distance of
these are calibrated, included in the chart and determine the Predicted levels of PM2.5 for
these.
Page 13-15, Figures 13.5 and 13.6 below only measures Total Suspended Particles and Peak PM10 assessed to distance but not for PM2.5 load which is much more harmful to human health in relation to distance from the edge of the proposed roadway. PM2.5 is the smaller particles that will remain airborne for longer and penetrate deeper into the lungs potentially causing more harm to health. Why haven’t the assessors shown PM2.5 as a function of distance from the road?
The EPA state on page 9 of their submission regarding the Mordialloc Freeway Environmental
Effects Statement (EES) under section titled 2.2.7. State Environment Protection Policy (Air
Quality Management) that assessments are made near roads: "In accordance with emerging
scientific evidence and best practice, EPA recommends the use of the SEPP (AAQ) Schedule 2 -
environment air quality objectives to compare and assess air pollution levels measured near
roads, instead of the SEPP (AQM) Intervention Levels."6
An Indoor Air Quality Study of residential dwellings that was carried out in Melbourne, Australia
found that dwellings in close proximity to major roads (less than 50 metres) found high levels of
indoor air pollutants89. Independent of gas cooking, "indoor NO 2 was elevated in Near Road
89 Sarah J. Lawson*, Ian E. Galbally, Jennifer C. Powell, Melita D. Keywood, Suzie B. Molloy, Min Cheng, Paul W.
Selleck. The effect of proximity to major roads on indoor air quality in typical Australian dwellings. Atmospheric
Environment, April 2011, Volume 45, Issue 13, p. 2252-2259.https://doi.org/10.1016/j.atmosenv.2011.01.024
The proposed freeway and attendant growth in vehicle emissions will expose local residents to
greater air pollution and health risks.
I am particularly concerned that the increase traffic related air pollution will affect the health of
susceptible groups; the elderly, children and pregnant women cyclists and pedestrians using the
freeway trail as well as workers in the local industrial region and the wider community.
There is strong evidence for causation or association of traffic related air pollution with
multiple adverse health outcomes, being dose dependent [even below current Government
standards] with different health outcomes depending on the duration of exposure:
Different health outcomes depending on duration of exposure - eg:
• Day(s), hours, minutes: Acute asthma, heart attacks, sudden death
• Weeks: Low birth weight pregnancy
• Chronic exposure: Cancer, cardio-vascular and chronic respiratory diseases
• There are multiple sources of air pollution but traffic related air pollution is an
important contributor
• Some people are more susceptible than others
• Australian research is consistent with international studies
Worldwide efforts by health authorities highlight concerns of communities living next to or
near highways or freeways, and impacts on health 92,93,94.
92
Living Near Highways and Air Pollution | American Lung Association https://www.lung.org/our-initiatives/healthy-air/outdoor/air-pollution/highways.html
93 Health Effects Institute https://www.healtheffects.org/ & https://www.healtheffects.org/air-pollution/traffic-
related-air-pollution
94 Issue air-pollution-and-its-health-impacts-changing-panorama | The Medical Journal of Australia Volume 177